Writing accurate deposition summaries is important, but something that many lawyers tend to shy away from. If you’ve never drafted a summary deposition before or you’re just looking for some pointers, here are a few easy tips to quickly get you started.


A deposition summary is a brief, one-page document that summarizes the testimony given in a deposition. It should include the following information:

1. The date of the deposition

2. The name of the witness and attorney who were present at the deposition

3. The attorney asking questions at the deposition

4. The attorney asking questions at the deposition

5. Questions asked by counsel and answers given by the witness


A deposition summary is useful and has the potential to be extremely powerful because 

  • it gives the audience the point of view that they would normally not have access to the actual testimony. 
  • it will clarify any questions or doubts readers may have. 

The Process

At the beginning of each deposition, there the following will happen:

1. The witness will be sworn in by the court reporter or judge. This means that they promise to tell the truth.

2. The court reporter will set up their equipment and record everything that happens during the deposition. They make notes as they go along so they can write down everything as it happens.

3. Witnesses give testimony under oath (meaning they have to tell the truth). They can’t make up things or lie because doing so would be perjury, which is illegal!

4: Attorney asks questions about relevant information related to case at hand; 

5. witness answers questions or provides further details when necessary

6. attorney cross examines if necessary; 

7. an attorney may ask other questions if they think they’re important enough to ask even though they don’t relate directly back to questions asked by the opposing side originally posed during direct examination (which is why this process can take hours, sometimes even days depending on how long the witness has spent answering questions already asked).

In conclusion, summarizing is one of the most time-consuming tasks that an attorney can take on. The above tips should help you save time and effort with every deposition you write. So before you spend another hour trying to figure out what to do, check these tips out—you might just find they make your life a lot easier!

Author bio: Sheila LaCivita earned a paralegal degree with distinction from UCLA and has been helping lawyers with deposition summaries. She wants to share her knowledge and experience with others.